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Czech Republic: Double Tax Treaties

Table of Treaty Rates

Provided by TreatyPro
Czech Republic


Jurisdiction Status Dividends Interest Royalties Notes
           
Defaults 15/35% (3) 15/35% (3) 15/35% (3)
           
Albania Effective January 1, 1997 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid by the government, or to the government or the central bank 5% 10%
Armenia Effective January 1, 2010 10% 0% when paid to the government or the central bank, or on a loan or credit guaranteed or insured by the government or the central bank 5% when paid on a bank loan or credit 10% 5% for copyright or broadcasting royalties 10%
Australia Effective January 1, 1996 5% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 15% 10% 10%
Austria Effective January 1, 2008 0% where the payee is a company holding at least 10% of the paying company's capital 10% 0% 0% for copyright or broadcasting royalties 5%
Azerbaijan Effective January 1, 2007 8% 0% when paid to the government or the central bank, or on a loan or credit guaranteed or insured by the government or the central bank 5% when paid on a bank loan or credit 10% 10%
Bahrain Effective January 1, 2013 5% 0% 10%
Barbados Effective January 1, 2013 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan or credit guaranteed by the government, or on a bank loan or credit, or on sales on credit of equipment or merchandise 5% 5% for copyright or broadcasting royalties 10%
Belarus Effective January 1, 1999 Protocol effective January 1, 2012 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 0% when paid to the government or the central bank, or on a bank loan or credit 5% 5%
Belgium Effective January 1, 2001 5% where the payee is a company holding at least 25% of the paying company's capital 15% 0% when paid to the government, or on commercial debt-claims resulting from payments for goods, merchandise or services, or on a loan or credit financed, guaranteed or insured by a public entity to promote exports, or on a bank loan or deposit not represented by bearer instruments 10% 5% for equipment royalties 10%
Bosnia and Herzegovina Effective January 1, 2011 5% 0% 0% for copyright or broadcasting royalties 10%
Brazil Effective January 1, 1991 15% 0% when paid to the government, or on government bonds, securities or debentures 10% when paid on a bank loan or credit granted for at least ten years in connection with the selling of industrial equipment or with the study, installation or furnishing of industrial or scientific units, as well as with public works 15% 15% (4) The Czechoslovakia treaty continues to apply.
Bulgaria Effective January 1, 2000 10% 0% when paid to the government or the central bank, or on a loan or credit guaranteed by the government, or on sales on credit of equipment or merchandise 10% 10%
Canada Effective January 1, 2003 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% 0% when paid to the government or a pension fund, or on a loan or credit financed, guaranteed or insured by a government institution in respect of imports or exports, or on sales on credit of equipment, merchandise or services 10% 10%
China Effective January 1, 2012 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 0% when paid to the government or the central bank, or on a loan or credit financed, guaranteed or insured by the government or the central bank 7.5% 10%
Colombia Signed March 22, 2012 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan or credit guaranteed by the government or the central bank, or on a bank loan or credit granted for at least three years, or on sales on credit of equipment or merchandise 10% 10% Not yet in force. Default rates apply.
Croatia Effective January 1, 2000 5% 0% 10%
Cyprus Effective January 1, 2010 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 12 months before payment of the dividend 5% 0% 0% for copyright or broadcasting royalties 10%
Denmark Effective January 1, 2013 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital, or a pension fund 15% 0% 0% for copyright or broadcasting royalties 10%
Egypt Effective January 1, 1996 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank 15% 15%
Estonia Effective January 1, 1996 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 10% 10%
Ethiopia Effective January 1, 2009 10% 0% when paid to the government or the central bank, or on a loan or credit guaranteed or insured by the government or the central bank 10% 10%
Finland Effective January 1, 1996 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0% for copyright or broadcasting royalties 1% for finance lease of equipment 5% for operating lease of equipment, or the use of any computer software 10%
France Effective January 1, 2006 0% where the payee is a company holding at least 25% of the paying company's capital 10% 0% 0% for copyright or broadcasting royalties 5% for equipment royalties 10%
Georgia Effective January 1, 2008 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 0% when paid to the government or the central bank, or on a loan or credit guaranteed by the government, or on sales on credit of equipment 8% 0% for copyright or broadcasting royalties 5% for equipment royalties 10%
Germany Effective January 1, 1984 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% 5% The Czechoslovakia treaty continues to apply.
Greece Effective January 1, 1990 15% (5) 0% when paid on a government or central bank loan 10% 0% for copyright or broadcasting royalties 10% The Czechoslovakia treaty continues to apply.
Hong Kong Effective January 1, 2013 5% 0% 10%
Hungary Effective January 1, 1995 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% 10%
Iceland Effective January 1, 2001 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 10%
India Effective January 1, 2000 10% 0% when paid to or on a loan or credit extended or endorsed by the government, the central bank or a specified institution 10% 10%
Indonesia Effective January 1, 1997 10% where the payee is a company holding directly at least 20% of the paying company's capital 15% 0% when paid to the government or the central bank 12.5% 12.50%
Ireland Effective January 1, 1997 5% where the payee is a company holding directly at least 25% of the paying company's voting stock 15% 0% 10%
Israel Effective January 1, 1995 5% where the payee is a company (excluding a partnership) holding directly at least 15% of the paying company's capital 15% 0% when paid on government bonds or debentures, or on a loan or credit financed, guaranteed or insured by the central bank 10% 5%
Italy Effective January 1, 1985 15% 0% 0% for copyright or broadcasting royalties 5% The Czechoslovakia treaty continues to apply.
Japan Effective January 1, 1979 10% where the payee is a company holding at least 25% of the paying company's voting stock for six months before payment of the dividend 15% 0% when paid to the government or the central bank, or on a loan or credit guaranteed or indirectly financed by the government or the central bank 10% 0% for copyright or broadcasting royalties 10% The Czechoslovakia treaty continues to apply.
Jordan Effective January 1, 2008 10% 0% when paid to the government or the central bank 10% 10%
Kazakhstan Effective January 1, 2000 10% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 10% 10%
Korea, North Effective January 1, 2006 10% 0% when paid on a government or central bank loan 10% 10%
Korea, South Effective January 1, 1996 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 0% when paid to the government or the central bank, or on a loan or credit guaranteed or indirectly financed by the government or the central bank, or on sales on credit of equipment or merchandise 10% 0% for copyright or broadcasting royalties 10%
Kuwait Effective January 1, 2005 0% where the payee is the government, the central bank or a company at least 25% owned by the government or the central bank 5% 0% 10%
Latvia Effective January 1, 1996 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 10% 10%
Lebanon Effective January 1, 2001 5% 0% 5% for equipment royalties 10%
Liechtenstein Signed September 25, 2014 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 12 months before payment of the dividend 15% 0% 10% Not yet in force. Default rates apply.
Lithuania Effective January 1, 1996 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 10% 10%
Luxembourg Effective January 1, 2015 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 12 months before payment of the dividend 10% 0% 0% for copyright or broadcasting royalties 10%
Macedonia Effective January 1, 2003 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 10%
Malaysia Effective January 1, 1999 10% 0% when paid to the government or the central bank 12% 12%
Malta Effective January 1, 1998 5% 0% 5%
Mexico Effective January 1, 2003 10% 0% when paid to the government or the central bank, or on a loan or credit financed, guaranteed or insured by the government or the central bank, or for at least three years by a specified institution 10% 10%
Moldova Effective January 1, 2001 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 5% 10%
Mongolia Effective January 1, 1999 10% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 10% 10%
Morocco Effective January 1, 2007 10% 0% when paid to the government or the central bank, or on a loan or credit guaranteed by the government 10% 10%
Netherlands Effective January 1, 1972 0% where the payee is a company holding directly at least 25% of the paying company's capital 10% 0% 5% The Czechoslovakia treaty continues to apply.
New Zealand Effective January 1, 2009 15% 0% when paid to the government or the central bank, or on a loan or credit financed, guaranteed or insured by a specified institution 10% 10%
Nigeria Effective January 1, 1991 12.5% where the payee is a company holding at least 10% of the paying company's voting stock 15% 0% when paid to the government or the central bank, or on a loan or credit approved by both governments in respect of external trade 15% 15% The Czechoslovakia treaty continues to apply.
Norway Effective January 1, 2006 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital, the government or the central bank 15% 0% 0% for copyright or broadcasting royalties 5% for equipment royalties 10%
Pakistan Signed May 2, 2014 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan or credit financed, guaranteed or insured by the government or the central bank 10% 10% Not yet in force. Default rates apply.
Panama Effective January 1, 2014 10% 0% when paid to the government or the central bank, or on a loan or credit guaranteed for at least four years by the government or the central bank, or on sales on credit of equipment or merchandise 5% when paid to a bank 10% 10%
Philippines Effective January 1, 2004 10% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan or credit guaranteed by the government 10% 10% 15% for broadcasting royalties
Poland Effective January 1, 2013 5% 0% when paid to the government or the central bank, or on a loan or credit guaranteed by the government or the central bank, or on a bank loan or credit 5% 10%
Portugal Effective January 1, 1998 10% where the payee is a company holding directly at least 25% of the paying company's capital for 24 months before payment of the dividend 15% 0% when paid to or by the government, or on a loan or credit financed by a specified institution, or on financing approved by both governments 10% 10%
Romania Effective January 1, 1995 10% 0% when paid to the government, or on a loan or credit financed, guaranteed or insured by the government 7% 10%
Russia Effective January 1, 1998 Protocol effective January 1, 2010 10% 0% 10%
Saudi Arabia Effective January 1, 2014 5% 0% 10%
Montenegro Effective January 1, 2006 10% 0% when paid to the government or the central bank 10% 5% for copyright or broadcasting royalties 10%
Singapore Effective January 1, 1999 Protocol effective January 1, 2015 5% 0% 0% for copyright or broadcasting royalties 5% for equipment royalties 10%
Slovakia Effective January 1, 2004 5% where the payee is a company (excluding a partnership) holding at least 10% of the paying company's capital 15% 0% 0% for copyright or broadcasting royalties 10%
Slovenia Effective January 1, 1999 5% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank 5% 10%
South Africa Effective March 1, 1998 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 10%
Spain Effective January 1, 1982 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 0% for literary, artistic, dramatic or musical copyright royalties (excluding broadcasting royalties) 5% The Czechoslovakia treaty continues to apply.
Sri Lanka Effective January 1, 1980 15% 0% when paid to the government or a bank 10% 0% for copyright or broadcasting royalties 10% The Czechoslovakia treaty continues to apply.
Sweden Effective January 1, 1981 0% where the payee is a company holding directly at least 25% of the paying company's capital 10% 0% 0% for copyright royalties 5% The Czechoslovakia treaty continues to apply.
Switzerland Effective December 1, 1996 Protocol effective January 1, 2014 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 12 months before payment of the dividend, a pension fund or the central bank 15% 0% 5%
Syria Effective January 1, 2010 10% 0% when paid to the government or the central bank, or on a loan or credit guaranteed by the government 10% 12%
Tajikistan Effective January 1, 2008 5% 0% when paid to the government or the central bank, or on a loan or credit guaranteed by the government or the central bank, or on a bank loan or credit, or on sales on credit of equipment or merchandise 7% 10%
Thailand Effective January 1, 1996 10% 0% when paid to the government or the central bank 10% when paid to a financial institution or insurance company 15% (5) 5% for copyright royalties (excluding broadcasting royalties) 10% for the use of any patent, trademark, design or model, plan, secret formula or process 15%
Tunisia Effective January 1, 1992 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid on a government approved loan 12% 5% for copyright or broadcasting royalties 15% The Czechoslovakia treaty continues to apply.
Turkey Effective January 1, 2004 10% 0% when paid to the government or the central bank 10% 10%
Ukraine Effective January 1, 2000 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 5% 10%
United Arab Emirates Effective January 1, 1998 0% where the payee is the government or a company at least 25% owned by the government 5% 0% 10%
United Kingdom Effective January 1, 1992 5% where the payee is a company holding at least 25% of the paying company's voting stock 15% 0% 0% for copyright or broadcasting royalties 10% The Czechoslovakia treaty continues to apply.
United States Effective February 1, 1994 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% 0% 0% for copyright or broadcasting royalties 10% Separate dividend withholding tax rules apply to REITs.
Uzbekistan Effective January 1, 2002 Protocol effective January 1, 2013 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 0% when paid to the government or the central bank, or on a loan or credit guaranteed or insured by the government or the central bank, or on a bank loan or credit, or on sales on credit of equipment or merchandise 5% 10%
Venezuela Effective January 1, 1998 5% where the payee is a company (excluding a partnership) holding directly at least 15% of the paying company's capital 10% 0% when paid to or by the government or the central bank, or on a loan financed or guaranteed by a government institution in respect of external trade 10% 12%
Vietnam Effective January 1, 1999 10% 0% when paid to the government or the central bank, or on a loan or credit approved by Czech Republic 10% 10%
Serbia Effective January 1, 2006 10% 0% when paid to the government or the central bank 10% 5% for copyright or broadcasting royalties 10%
Kosovo Signed November 26, 2013 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% 10% Not yet in force. Default rates apply.

Footnotes

  1. In the case of European Union countries, the EC Parent-Subsidiary Directive can reduce dividend withholding tax to 0%, subject to certain conditions.
  2. In the case of European Union countries, the EC Interest and Royalties Directive can reduce interest and royalties withholding tax to 0%, subject to certain conditions.
  3. Czech Republic may increase its dividend, interest and royalty withholding taxes to 35% in the case of a jurisdiction classed as a low tax jurisdiction.
  4. The treaty specifies a different rate but the default rate is lower and would therefore apply.
  5. The domestic rate applies.
  6. PLEASE NOTE: This table was last updated February 2015

 

 

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